Technical Service Providers

What do I need to know?

The IAEA has laid forth the fundamental safety objective and ten associated safety principles in Fundamental Safety Principles, IAEA Safety Standards Series NO. SF-1. Furthermore, in the IAEA Safety Standards Series, General Safety Requirements Part 3., the fundamentals of radiation protection and safety of radiation sources can be found. From a regulatory standpoint, technical service providers behave similarly to operators and employers in the nuclear industry. The key understanding for a technical service provider is whether the employees are being occupationally exposed to radiation. This will determine what sort of regulations and rules are placed upon the TSP.

General Considerations

“Any technical service providers for protection and safety should be qualified by certain procedures.” – GSG 7 Paragraph 8.1

The management system for service providers in radiation protection and safety should be graded to the scope of their activities. Additionally, it must document its management system to the extent necessary to ensure the quality of the service provided. This management system should cover work carried out in permanent facilities, at sites away from permanent facilities, or in associated temporary or mobile facilities. This management system should meet the requirements and recommendations of all relevant IAEA safety standards [5,6].

Safety Culture

For a service provider, safety culture should be established by:

1. Promoting the knowledge of relevant safety standards within the organization;
2. Carrying out a risk analysis of the procedures applied;
3. Establishing proper rules and procedures, and observing regulatory requirements to keep risks at a minimum;
4. Periodically evaluating the implementation and effectiveness of these rules and procedures;
5. Engaging the relevant management and staff;
6. Periodically training the staff, in accordance with an established training programme, to follow the rules and procedures correctly;
7. Discussing the established training programme with trained staff;
8. Periodically updating the training programmes and coordinating them with the requirements of legal and regulatory bodies, which should check the effectiveness of these programmes;
9. Disseminating and promoting knowledge of accidents and other incidents to learn from their occurrence, and any reoccurrence, and to improve the safety culture;
10. Eliciting safety related proposals from the staff through an incentive system.

Documentation of the management system

Documents^1/ may be organized in any relevant medium used in the organization provided that an appropriate system of control is used.

The documentation of the management system is often contained in a quality manual that includes, or that makes reference to, the supporting documents, including:

1. A description of the management system.
2. Management documents, for instance documents relating to some of the topics covered in paras 8.49–8.70 of GSG-7.
3. Detailed work processes and job descriptions.
4. Additional technical documents and data, including: (i) Databases of radionuclides and technical databases:
    
   1. Operating manuals for equipment and software;
   2. Reagent data sheets;
   3. Requirements of the regulatory body or other relevant authority (as established in laws and regulations);
   4. Managerial and technical standards.

The additional technical documents are often external documents that are not within the scope of influence of the service provider. Nevertheless, these documents and data should also be controlled.

The procedure that describes how documents are to be controlled within the organization should include a periodic review of valid documents to determine whether an update (revision) may be necessary.

Dose Management System

“Employers, registrants and licensees shall be responsible for making arrangements for assessment and recording of occupational exposures and for workers’ health surveillance.” – GSR Part 3 Requirement 25

In GSR Part 3 Requirement 25, the employer, licensee, and registrant’s responsibilities relevant to the assessment and recording of occupational exposures for workers’ health surveillance are laid forth. This includes the need for keeping records of occupational exposure. Paragraphs 3.103- 3.107 explain what this responsibility entails. Some of these requirements include:

1. Records of occupational exposure for each worker shall be maintained during and after the worker’s working life, at least until the former worker attains or would have attained the age of 75 years, and for not less than 30 years after cessation of the work in which the worker was subject to occupational exposure.
2. Records of occupational exposure shall include:
    
   1. Information on the general nature of the work in which the worker was subject to occupational exposure;
   2. Information on dose assessments, exposures and intakes at or above the relevant recording levels specified by the regulatory body and the data upon which the dose assessments were based;
   3. When a worker is or has been exposed while in the employ of more than one employer, information on the dates of employment with each employer and on the doses, exposures and intakes in each such employment;
   4. Records of any assessments made of doses, exposures and intakes due to actions taken in an emergency or due to accidents or other incidents, which shall be distinguished from assessments of doses, exposures and intakes due to normal conditions of work and which shall include references to reports of any relevant investigations.
       
3. Employers, registrants and licensees:
    
   1. Shall provide workers with access to records of their own occupational exposure;
   2. Shall provide the supervisor of the programme for workers’ health surveillance, the regulatory body and the relevant employer with access to workers’ records of occupational exposure;
   3. Shall facilitate the provision of copies of workers’ exposure records to new employers when workers change employment;
   4. Shall make arrangements for the retention of exposure records for former workers by the employer, registrant or licensee, as appropriate;
   5. Shall, in complying with (a)–(d) above, give due care and attention to maintaining the confidentiality of records.
       
4. If employers, registrants and licensees cease to conduct activities in which workers are subject to occupational exposure, they shall make arrangements for the retention of workers’ records of occupational exposure by the regulatory body or a State registry, or by a relevant employer, registrant or licensee, as appropriate.

References

• Radiation Protection and Safety of Radiation Sources: International Basic Safety Standards, IAEA Safety Standards Series No. GSR Part 3, IAEA, Vienna (2014)
• Occupational Radiation Protection, IAEA Safety Standards Series No. GSG-7, IAEA, Vienna (2018) 

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^1/ Documents may include: policies; procedures; instructions; specifications and drawings (or representations in other media); training materials; and any other texts that describe processes, specify requirements or establish product specifications.